HRIF.EU Calls for Halt to forbidden outsourced Transaction Monitoring in the Netherlands

Human Rights in Finance.EU (HRIF.EU) this week requested bank-owned company ‘Transactie Monitoring Nederland’ (TMNL) to cease processing transactions on behalf of five major banks and to discard all associated data. This request follows a petition presented to the Dutch Parliament on behalf of a number of advocacy groups such as Privacy First, Bits of Freedom, and nearly 15,000 bank customers.

In the petition, HRIF.EU urged the Dutch Parliament to intervene and halt TMNL’s operations. Subsequently, we called upon the Dutch National Bank (DNB) to enforce anti-money laundering regulations upon the banks. However, responses to these calls have been minimal, both from DNB and the Dutch Parliament.

Upon receiving a bank account for the foundation itself, we initiated transactions between various accounts, seeking insight into TMNL’s data processing under GDPR regulations. The response to our inquiry was unsatisfactory, and the unlawful processing and transaction monitoring persist.

It’s time to halt these privacy and human rights violations!

HRIF.EU investigated the scale of transactions and data subjects involved in TMNL’s processing. Research from the Dutch Payment Association indicates approximately 1.95 billion business transactions annually, roughly 5 million per day, assuming the majority involve the five major banks.

When TMNL proved uncooperative with our request for transparency, we escalated our efforts. Politely reiterating our request, we also formally objected to further processing and demanded the destruction of all data, two elemental rights under GDPR that serve human rights protection.

Furthermore, we highlighted that TMNL lacks a legal basis for its processing activities. Sharing bank data, the raw material of its operation, violates anti-money laundering regulations (Article 10). TMNL effectively operates as an illegal data broker/processor. Bank employees found accessing such data in breach of regulations face professional sanctions. Why should TMNL be treated differently?

You can read our entire (sorry: in Dutch) correspondence with Transactie Monitoring Nederland here. Privacy professionals may find interesting themes therein (to be or not to be: joint processing, is that the question?), including our focus on human rights.

Can you help?


You can voice your opinion and support by sending us a message. Wouldn’t it be great if banks involved with TMNL also took note? It’s time they understand that the Netherlands is ready to end transaction monitoring. And don’t they monitor the payment description field as a daily activity?

Therefore, if you feel inclined, express your support by sending a one-cent euro payment (or more if your bank requires) to bank account NL94 TRIO 0320 7857 85, payable to Human Rights in Finance.EU, and share your thoughts in the payment’s description field.